Privacy statement HAAVENS B.V.

Introduction and purpose of the privacy statement

Haavens B.V. (Haavens, hereinafter also referred to as ‘we’, ‘us, ‘our’) acts as a property manager in the Netherlands. In order to carry out our activities, we collect, save and use personal data and/or use that data in other ways. This is also called ‘processing’ personal data.

Based on the applicable privacy and data protection legislation and regulations, including the General Data Protection Regulation (GDPR), we are regarded as a ‘controller’ with regard to your personal data that we process.

Haavens understands that you value your privacy and would like to know how we use your personal data. We respect your privacy and only use your personal data in the manner and for the purposes described in this privacy statement. Obviously, we take our obligations and your rights into account.

We recommend that you read this privacy statement carefully. Here below, you will be informed, among other things, about:

  • what personal data of yours we may collect/use and how we do it;
  • on what legal basis we process personal data;
  • for what purposes and how we process personal data and with whom we share it;
  • how long we keep your personal data; and
  • what rights you have under privacy legislation and regulations.

It may be necessary to amend this privacy statement from time to time. For example, due to a change in the law or when we change our business operations or activities in such a way that this affects how we process personal data and/or which personal data we process. In the event of material or substantial changes, we will actively notify you by providing you with a new version of the privacy statement.

The current version of this privacy statement can always be found on our website: https://www.haavens.nl. You can also ask us to send you a copy of the most recent privacy statement (free of charge). You can address this request and other privacy-related questions to privacy@haavens.nl.

Who are we?

Haavens B.V. with its registered office in (1076 ER) Amsterdam, at Burgerweeshuispad 101 and registered in the trade register of the Chamber of Commerce under number 74391135. As a property manager, we focus on acquiring, managing, operating, renovating, renting out and investing in homes in the Netherlands.

Whose personal data do we process?

In the context of our activities, we collect personal data from the following persons:

  • Representatives, contacts and/or other employees of our current and former contract and business partners, including suppliers, contractors and Haavens affiliates;
  • Representatives, contacts and/or other employees of our current and former legal and other advisers, consultants, accountants and other service providers;
  • Representatives, directors and/or other employees of our shareholder(s);
  • Parties from whom we buy or may buy real estate or to whom we sell real estate and their representatives;
  • Neighbours of the properties we manage; and
  • Illegal residents of the properties we manage.

Please note: this privacy statement does not apply to tenants of the property we manage, employees and job applicants. They will receive a separate privacy statement from us.

When you provide us with personal data of someone other than yourself, for example, of the legal representative of the company you work for, we request that you provide that person with a copy of this privacy statement before you provide their data to us.

How do we collect your personal data?

We may obtain your personal data in several ways:

  • Directly from you, for example, when you send us an email or give us a business card containing your personal data;
  • From third parties, for example, when we receive your contact details from one of your colleagues or our business partners; and
  • From public sources, including the land registry, the trade register, the RDW (Dutch vehicle registration system), BRP (Dutch Personal Records Database) or your own website or social media account.

Specific information about the processing of your personal data

Below you will find an overview of the purposes for which we process your personal data. It is always indicated which data we use for that specific purpose, what the legal basis is for processing that data and how long we keep the personal data. To ensure that you can quickly find which data of yours we may process, we have included this information per type of processing activity and in table form.

Please note that when we process your personal data based on your consent, you can withdraw this consent at any time by contacting privacy@haavens.nl. However, this does not affect the lawfulness of processing your personal data before the withdrawal of your consent.

Establishing and maintaining contacts with business clients

Purposes Establishing and maintaining business relationships, including relationships with our property manager, contacts with consultants, legal advisers, accountants, suppliers (office supplies, etc.) and contractors or maintenance companies. In this context, personal data is required for communication about the services that are provided back and forth, performing the contracts and for Haavens’ business operations and business continuity.
Categories of personal data Name, company name (employer), position/title and business contact details (email address, telephone number, etc.) and possibly signatures.
Grounds Legitimate company and other interests of Haavens and the performance of business agreements.
Retention period In principle, Haavens stores the personal data for the duration of the business relationship and (if earlier) until the end of the employment and/or involvement of the contact person at the Haavens business contact. In some cases, Haavens may keep the personal data for longer, i.e. if it is legally obliged to do so or if it has other good reasons to keep the personal data longer, such as defending its rights in a legal dispute or imminent legal dispute.

Establishing and maintaining contacts with shareholders

Purposes In this context, Haavens collects and uses personal data of its shareholder(s) to communicate in the context of business operations and reporting to shareholder(s).
Categories of personal data Name, company name (employer), position/title and business contact details (email address, telephone number, etc.). Haavens also has a copy of the directors’ passports and their signatures.
Grounds Legitimate company and other interests of Haavens, executing corporate shareholder and other agreements and complying with legal obligations (with regard to shareholders).
Retention period In principle, Haavens stores the personal data for the duration of the shareholder relationship and (if earlier) until the end of the employment with and/or involvement of the contact person at the shareholder(s) of Haavens. In some cases, Haavens may keep the personal data for longer, namely if Haavens is legally obliged to do so or if it has other good reasons to keep the personal data longer, such as defending its rights in a legal dispute or imminent legal dispute.

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Due diligence and transactions

Purposes Haavens processes personal data in the context of due diligence and (possibly subsequent transactions) with regard to the acquisition of new residential portfolios and the associated KYC process.
Categories of personal data Name, company name (employer), position/title, business contact details (email, telephone number, etc.), signature(s), copy of passport (including information about race and ethnic origin insofar as this is apparent from the passport/photo in it), data from public sources, such as the Chamber of Commerce and, if the seller is a private individual, bank and payment details and billing address.
Grounds Legitimate business and other interests of Haavens.
Retention period In principle, Haavens keeps the personal data for a period of ten years after the transaction is closed or the transfer of ownership (in connection with the review period), or any longer as necessary with a view to a legal dispute, imminent or otherwise.

Contact form on Haavens’ website

Purposes For the purpose of communication with potential tenants, neighbours who have complaints about or experience nuisance from tenants of the properties we manage, and any other parties who use the contact form (or the general email address), personal data are processed that are provided to Haavens by completing and sending the contact form (and possibly in the follow up).
Categories of personal data Name, address, email address, telephone number, personal data that follow from the content of the message and whether or not the person who makes contact is a tenant of Haavens.
Grounds Legitimate interests of Haavens to be able to communicate with the user and to handle requests made via the contact form.
Retention period In principle, Haavens keeps the personal data until the question or complaint submitted via the contact form has been dealt with, or longer if necessary for an expected legal procedure.

Housing fraud – Unlawful habitation

Purposes To end an illegal subletting or other situation and communication with illegal residents.
Categories of personal data Name, address/residence, email address and telephone number.
Grounds Legitimate interests of Haavens to end the unlawful situation and to prevent or limit financial and other damage.
Retention period In principle, Haavens stores the personal data until the unlawful situation has been ended and settled or longer if necessary in an expected legal procedure.

Do we share your contact details with others?

We sometimes share your personal data with third parties, but only if and to the extent that this is necessary for the performance of the above purposes or if we are obliged to do so under applicable legislation and regulations or an agreement.

We sometimes share your personal data with:

  • our service providers, such as our IT service providers, software providers;
  • external advisers, such as legal advisers, accountants, banks, insurers, experts, bailiffs and collection agencies;
  • Blackstone, the manager of the funds that owns the properties we manage; and
  • Haavens affiliates and our shareholders (Overflow B.V. / DTK JV B.V., Rivierenbuurt Vastgoed B.V.).

We may also pass on your personal data to third parties in the event of a full or partial sale or transfer of Haavens B.V. if this is necessary in the context of that transaction.

Finally, we may be legally obliged to share your personal data, for example with the tax authorities, when we are involved in legal proceedings or have to comply with a court decision or instructions from an insurer or government agency (such as the Dutch Data Protection Authority). Another example of this is that the police could request personal data from us in the context of an investigation.

When we pass on your personal data to third parties, we ensure that the necessary security measures are taken. For example, we will enter into a processing agreement where necessary. In that agreement we include restrictions with regard to the use of your personal data, and we impose obligations on the receiving party in the context of protecting your personal data.

Transfer to parties in a third country or international organisation

In some cases, we share your personal data with recipients located outside the European Economic Area (EEA). We only transfer your personal data outside the EEA in the following situations:

  • In reports and/or meetings regarding situations that concern the property owners. In this case, personal data may be exchanged with Blackstone, the manager of the funds that owns the property.

Since the privacy protection regulations in third countries may not offer the same level of protection as the regulations within the EEA, Haavens will ensure that appropriate measures are taken in these cases to protect your personal data in accordance with applicable legislation. We will (if necessary and where possible) use the EU Model Clauses to protect your personal data. You can request us to provide you with a copy of the appropriate safeguards that have been put in place. If that is not possible, we may ask you for permission to transfer your personal data to countries without an adequate level of protection. You can also withdraw this permission at any time.

Your rights

Under certain circumstances, you have the following rights in relation to your personal data:

  • Receipt of additional information regarding the processing of your personal data
  • Right to inspect your personal data that we have (access request)
  • Correction of your personal data
  • Deletion of your personal data
  • Objecting to the processing of your personal data or some of it
  • Restricting processing of your personal data or some of it;
  • Transferability of your data from us to you, if you have not provided this data to us yourself.

If you request access, this must be submitted to us in writing (by email or post). In principle, we do not charge any costs for an access request. However, we may charge you a fee for our administrative costs if your request is ‘manifestly unfounded or excessive’ (for example, where you make unnecessarily repetitive requests). After receiving your access request, you will receive our response within one month. We will try to provide you with a complete response within this period, including a copy of your personal data. However, we need more time in some cases, especially when your request is more complex. In that case, you will receive our response within a maximum of three months from the date of receipt of your request. Obviously, we will keep you informed of the progress.

Finally, you always have the right to submit a complaint to the Dutch Data Protection Authority.

Our contact details

To contact us about anything related to your personal data and/or data protection, including exercising your data subject rights as discussed above, please use the contact details below:

Haavens B.V.

privacy@haavens.nl